NHTSA Interpretation File Search
Overview
NHTSA's Chief Counsel interprets the statutes that the agency administers and the standards and regulations that it issues. Members of the public may submit requests for interpretation, and the Chief Counsel will respond with a letter of interpretation. These interpretation letters look at the particular facts presented in the question and explain the agency’s opinion on how the law applies given those facts. These letters of interpretation are guidance documents. They do not have the force and effect of law and are not meant to bind the public in any way. They are intended only to provide information to the public regarding existing requirements under the law or agency policies.
Understanding NHTSA’s Online Interpretation Files
NHTSA makes its letters of interpretation available to the public on this webpage.
An interpretation letter represents the opinion of the Chief Counsel based on the facts of individual cases at the time the letter was written. While these letters may be helpful in determining how the agency might answer a question that another person has if that question is similar to a previously considered question, do not assume that a prior interpretation will necessarily apply to your situation.
- Your facts may be sufficiently different from those presented in prior interpretations, such that the agency's answer to you might be different from the answer in the prior interpretation letter;
- Your situation may be completely new to the agency and not addressed in an existing interpretation letter;
- The agency's safety standards or regulations may have changed since the prior interpretation letter was written so that the agency's prior interpretation no longer applies; or
- Some combination of the above, or other, factors.
Searching NHTSA’s Online Interpretation Files
Before beginning a search, it’s important to understand how this online search works. Below we provide some examples of searches you can run. In some cases, the search results may include words similar to what you searched because it utilizes a fuzzy search algorithm.
Single word search
Example: car
Result: Any document containing that word.
Multiple word search
Example: car seat requirements
Result: Any document containing any of these words.
Connector word search
Example: car AND seat AND requirements
Result: Any document containing all of these words.
Note: Search operators such as AND or OR must be in all capital letters.
Phrase in double quotes
Example: "headlamp function"
Result: Any document with that phrase.
Conjunctive search
Example: functionally AND minima
Result: Any document with both of those words.
Wildcard
Example: headl*
Result: Any document with a word beginning with those letters (e.g., headlamp, headlight, headlamps).
Example: no*compl*
Result: Any document beginning with the letters “no” followed by the letters “compl” (e.g., noncompliance, non-complying).
Not
Example: headlamp NOT crash
Result: Any document containing the word “headlamp” and not the word “crash.”
Complex searches
You can combine search operators to write more targeted searches.
Note: The database does not currently support phrase searches with wildcards (e.g., “make* inoperative”).
Example: Headl* AND (supplement* OR auxiliary OR impair*)
Result: Any document containing words that are variants of “headlamp” (headlamp, headlights, etc.) and also containing a variant of “supplement” (supplement, supplemental, etc.) or “impair” (impair, impairment, etc.) or the word “auxiliary.”
Search Tool
NHTSA's Interpretation Files Search
| Interpretations | Date |
|---|---|
ID: aiam1006OpenMr. Carl Monk, 428 Southland Boulevard, Louisville, Kentucky 40214; Mr. Carl Monk 428 Southland Boulevard Louisville Kentucky 40214; Dear Mr. Monk: Dr. Brinegar asked that I review and respond to your letter of Decembe 23, 1972, regarding warning devices.; As you know from previous correspondence, the National Highway Traffi Safety Administration (NHTSA) issued a Notice of Proposed Rule Making on a standard for warning devices in November 1970. One of our major concerns in issuing this standard was the great variety of warning devices of all sizes, shapes, forms and configurations that were available to the motoring public. While many of these provided varying degrees of effectiveness, the great variety also created confusion and misunderstanding to the motoring public. Standardization of these devices was therefore of prime importance.; In response to this notice many comments, designs and recommendation were suggested for inclusion in the standard. All responses were carefully reviewed and evaluated before we issued the final rule in March 1972. Federal Motor Vehicle Safety Standard No. 125 represents an attempt to achieve a balance between many factors including shapes, size, cost, visibility, stability and weight. Since these triangle are designed for ultimate use in all kinds of vehicles, from passenger cars to heavy trucks, we had to be careful not to specify requirements that would put them beyond the reach of the average motoring public.; We are appreciative of your comments to the docket and your subsequen correspondence of the Department of Transportation, regarding the wind stability requirement of the device. Vehicles traveling at 70 mph do not create an effective wind velocity of 70 mph off the roadside. Research data shows that warning devices designed to withstand wind velocities of approximately 40 mph will be sufficient for the majority of wind conditions created by truck turbulence and atmospheric wind velocities without unnecessary penalties in weight and cost. However, Standard No. 125 will in no way restrict the manufacture and sale of devices with higher wind-resistance capabilities for special uses. These are *minimum* standards.; Again, we appreciate your interest in this aspect of motor vehicle safety. it is the ideas and opinions of concerned individuals, such as yourself, that enable us to ensure rules and regulations that are meaningful and worthwhile to the motoring public. Thank you for writing E.T. Driver, Director, Office of Operating Systems, Motor Vehicle Programs; |
|
ID: aiam4204OpenMr. T. E. McConnell, Prince Lionheart, 2301 Cape Cod Way, Santa Ana, CA 92703; Mr. T. E. McConnell Prince Lionheart 2301 Cape Cod Way Santa Ana CA 92703; Dear Mr. McConnell: Thank you for your letter of July 31, 1986, inquiring about the Federa safety standards that apply to roll-up window shades designed to be attached to a vehicle's window by suction cups. The following discussion explains how our safety standards apply to your products.; Some background information on how Federal motor vehicle safety law and regulations affect your product may be helpful. Our agency is authorized, under the National Traffic and Motor Vehicle Safety Act, to issue safety standards applicable to new motor vehicles and certain items of motor vehicle equipment. NHTSA, however, does not approve motor vehicles or motor vehicle equipment, nor do we endorse any commercial products. Instead the Vehicle Safety Act establishes a 'self-certification' process under which each manufacturer is responsible for certifying that its products meet all applicable safety standards. The agency periodically tests vehicles and equipment items for compliance with the standards, and also investigates other alleged safety-related defects. As explained below, installation of products in new and used vehicles would be affected by our regulations. In addition, any manufacturer of motor vehicle equipment is subject to the requirements of the Vehicle Safety Act concerning the recall and remedy of products with noncompliances or defects related to motor vehicle safety.; We have issued Federal Motor Vehicle Safety Standard No. 205, *Glazin Materials*, which specifies performance and location requirements for glazing used in vehicles. These requirements include specifications for minimum levels of light transmittance (70% in areas requisite for driving visibility, which includes all windows in passenger cars).; No manufacturer or dealer is permitted to install solar films and othe sun screen devices, such as the ones described in your letter, in *new* vehicles without certifying that the vehicle continues to be in compliance with the light transmittance and other requirements of the standard.; After a vehicle is first sold to a consumer, modifications to a vehicl are affected by section 108(a)(2)(A) of the Vehicle Safety Act. That section prohibits commercial businesses from tampering with safety equipment installed on a vehicle in compliance with our standards. Thus, no dealer, manufacturer, repair business or distributor can install a sun screen device for the owner of the vehicle, if the device would cause the window not to meet the requirements of Standard No. 205. Violation of the 'render inoperative' provision can result in Federal civil penalties of up to $1,000 for each violation.; Section 108(a)(2)(A) does not affect vehicle owners, who may themselve alter their vehicles as they please, so long as they adhere to all State requirements. Under Federal law, the owner may install sun screening devices regardless of whether the installation adversely affects the light transmittance. Individual States govern the operational use of vehicles by their owners and therefore it is within the authority of the States to preclude owners from using sun screens in their vehicles.; I am returning, under separate cover, the two samples you provided th agency. If you need further information, please let me know.; Sincerely, Erika Z. Jones, Chief Counsel |
|
ID: aiam0247OpenMr. Philip N. Shrake, Recreational Vehicle Institute, Inc., 2720 Des Plaines Avenue, Des Plaines, IL 60018; Mr. Philip N. Shrake Recreational Vehicle Institute Inc. 2720 Des Plaines Avenue Des Plaines IL 60018; Dear Mr. Shrake: This is in response to your letter of July 23, 1970, in which you aske for the Bureau's interpretation of the phrase, 'designated seating position that includes the windshield header within the head impact area.'; The phrases 'designated seating position' and 'head impact area' ar both defined in the general Definitions section of the standards, 49 CFR 571.3. The remaining substantive phrase, 'windshield header,' is not defined in the standards. It is intended to refer to the portion of the interior of the vehicle immediately above the top of the windshield, usually but not necessarily a strip a molding separating the glass from the interior roof.; Sincerely, Rodolfo A. Diaz, Acting Associate Director, Motor Vehicl Programs; |
|
ID: aiam5045OpenMr. Leonard Marks 211 East Grand Avenue Old Orchard Beach, ME 04064; Mr. Leonard Marks 211 East Grand Avenue Old Orchard Beach ME 04064; "Dear Mr. Marks: This responds to your letter asking how the laws an regulations administered by this agency would apply to a device you intend to market. According to your letter, this device is 'a new adjustable attachment to seat belts which allows the user to lower the level so that it will no longer cut them in the neck and yet give them the safety of the belt.' I am pleased to provide the following information. It is not entirely clear how your proposed device would work. However, we have explained how our regulations apply to several different types of belt positioning devices. One such device is a 'comfort clip,' which is attached to the safety belt and can be positioned by an occupant to introduce and maintain slack in the belt system by physically preventing the belt slack from being taken in by the belt's retractor. We have explained how our regulations apply to comfort clips in a February 7, 1986 letter to Mr. Lewis Quetel (copy enclosed). Another device is one that clips the shoulder belt to the lap belt nearer the middle of the wearer's abdomen. We have explained how our regulations apply to these belt positioning devices in a February 11, 1988 letter to Mr. Roderick Boutin (copy enclosed). Yet another device is a covered foam pad that is fastened around the belt. We have explained how our regulations apply to these devices in a November 22, 1988 letter to Ms. Claire Haven (copy enclosed). Since your device would be considered 'motor vehicle equipment,' within the meaning of the National Traffic and Motor Vehicle Safety Act, I have also enclosed an information sheet for new manufacturers of motor vehicle equipment. This information sheet also explains how to get copies of our regulations. As you will see from reviewing the enclosed letters, aftermarket sales and installation by individual vehicle owners of devices to reposition belts are not prohibited by any Federal statutory or regulatory requirements. Nevertheless, the use of such devices could raise serious safety concerns if the devices inadvertently reduce the safety protection afforded by the original equipment safety belts. I hope this information is helpful. If you have any further questions or need some additional information, please feel free to contact Steve Kratzke of my staff at this address or by telephone at (202) 366-2992. Sincerely, Paul Jackson Rice Chief Counsel Enclosures"; |
|
ID: aiam2386OpenMr. Joseph G. Bishop, President, W.S. Coach Corp., Suite 100 Brookhaven Office Park, 3001 LBJ Freeway, Dallas TX 75234; Mr. Joseph G. Bishop President W.S. Coach Corp. Suite 100 Brookhaven Office Park 3001 LBJ Freeway Dallas TX 75234; Dear Mr. Bishop: This is in response to your July 7, 1976, request for informatio regarding the applicability of Federal motor vehicle safety standards to 'rumble seat kits' for installation in passenger cars. The answers to your questions are as follows:; (1) 'Is there any Federal Motor Vehicle Safety Standards or Regulation that would preclude the installation of rumble seats in passenger cars?'; >>>The answer to your question is no.<<< (2) 'What are the current Federal Motor Vehicle Safety Standards an Regulations that would be specifically applicable to the installation of rumble seats in passenger cars?'; >>>Installation of the rumble seats could affect compliance of th vehicle with the following safety standards: Standard No. 207, *Seating Systems*, Standard No. 208, *Occupant Crash Protection*, Standard No. 209, *Seat Belt Assemblies*, Standard No. 210, *Seat Belt Assembly Anchorages*, and Standard No. 110, *Tire Selection and Rims*.; We are assuming that the rumble seats would be installed in complete vehicles that are already certified, in which case the alterer would be required to meet the requirements of 49 CFR Part 567. Section 567.7 requires one who alters a previously certified vehicle, prior to its first sale, (by other than readily attachable components) to affix an additional label to the vehicle, stating that the vehicle remains in compliance with all applicable safety standards after the alteration. It should be noted that any additional weight created by the rumble seats or a change in the distribution of weight could also affect the vehicle's compliance with other safety standards whose test procedures require a barrier crash test.; We also would point out that 49 CFR Part 575 requires manufacturers t provide consumer information regarding vehicle stopping distance, tire reserve load, and acceleration and passing ability, at the point of first sale of the vehicle and along with the purchased vehicle. The increased weight created by the rumble seats could require modification of the information that would have to be provided.<<<; (3) 'Is there any State or Local Motor Vehicle Safety Standards that t your knowledge may preclude the installation of rumble seats in passenger vehicles?'; >>>We are not aware of any State or local regulations that woul preclude installation of rumble seats in passenger vehicles.<<<; (4) Can you furnish a list of Government approved independent testin facilities for FMVSS compliance testing?'; >>>The National Highway Traffic Safety Administration (NHTSA) does no approve independent testing facilities, nor will it recommend that any particular testing center be utilized. You might wish to contact the American Association of Motor Vehicle Administrators concerning this subject, at 1201 Connecticut Avenue, N.W., Washington, D.C.<<<; (5) 'Can the NHTSA make any design recommendations related to th installation of rumble seats in passenger vehicles?'; >>>The NHTSA does not provide engineering expertise regarding th manufacture of motor vehicles or motor vehicle equipment. However, the agency will answer specific questions that a manufacturer might have concerning the basis for a particular performance requirement.<<<; (6) 'Is there any future or pending legislation that may be related t the installation of rumble seats in passenger vehicles?'; >>>At the present time there is no pending Federal legislation relatin to the installation of rumble seats in passenger vehicles, nor is any such legislation anticipated by the NHTSA in the immediate future.<<<; The statements made above are directed primarily to the situation i which rumble seats would be installed prior to first sale of the vehicle, and in which the vehicle would have to be certified as being in compliance with all applicable motor vehicle safety standards. Please note, however, that the aftermarket installation of rumble seats might also be subject to Federal requirements.; Section 108 (a) (2) (A) of the National Traffic and Motor Vehicl Safety Act of 1966 provides that, with one exception, 'no manufacturer, distributor, dealer, or motor vehicle repair business shall knowingly render inoperative, in whole or part, any device or element of design installed on or in a motor vehicle or item of motor vehicle equipment in compliance with an applicable Federal motor vehicle safety standard. . . .' Therefore, no manufacturer, distributor, dealer, or repair business may install the rumble seats in a motor vehicle if he knows that such installation would alter the vehicle's compliance with any safety standard. For example, installation of rumble seats could possibly affect components of the vehicle that are subject to the requirements of safety standards such as Standard No. 108, *Lamps, Reflective Devices, and Associated Equipment*, or Standard No. 301, *Fuel System Integrity*.; Sincerely, Frank Berndt, Acting Chief Counsel |
|
ID: aiam0641OpenMr. W. G. Milby, Project Engineer, Blue Bird Body Company, Fort Valley, GA 31030; Mr. W. G. Milby Project Engineer Blue Bird Body Company Fort Valley GA 31030; Dear Mr. Milby: This is in response to your letter of February 7, 1972, in which yo discussed some problems that you have encountered with the regulation on vehicles manufactured in two or more stages (49 CFR Part 568), as applied to the school buses of which you are the final-stage manufacturer. Since the receipt of your letter, Mr. Rumph of your company and Mr. Sweet of the Truck Body and Equipment Association met with Mr. Dyson of this office to discuss the issues raised in your letter. Also, on March 8 you sent a sample letter that you proposed to send to your customers.; As we understand the problem from your letter and the subsequen discussion, it is essentially that you are receiving chassis-cowls from school bus buyers, for mounting of your bodies as a final-stage manufacturer, which are inadequate for the purpose according to the gross vehicle and gross axle weight ratings now included with the incomplete vehicles under our multistage vehicle regulations, 49 CFR Part 568. The problem as you describe it appears to have arisen in the negotiation between the school bus buyers and the dealers from whom they bought the incomplete vehicles, in that the dealers sold chassis that were too lightly equipped with tires and axles for the loaded weight implicit in the buyer's specification, under both our certification regulations and accepted industry practice. You state that your company bears the immediate burden of the problem, because you have invested in the production of several dozen bodies whose installation is held up pending resolution of the problem.; From your discussion we assume that all parties are agreed that th bodies that the customers ordered (and you have built) are the ones that are to be used, and that the chassis that have been furnished to you can be economically modified to meet the requirements of our regulations and be safe for their intended use.; With these assumptions, we suggest the following course of action o your part:; 1. Complete each vehicle as planned. 2. Affix a certification label to each vehicle as you normally do stating on the label weight rating figures that will satisfy our regulations (Part 567) and the axle capacity requirements of the vehicle.; 3. Deliver the vehicle, but concurrently send a written statement b certified mail to the vehicle buyer to the effect that the vehicle *must be modified* in order to conform to the GVWR and GAWR figures on the certification label, both for purposes of safety and to conform to Federal regulations. The letter should advise the buyer to take the vehicle to a dealer of the chassis manufacturer for these modifications immediately upon receiving it. The sample letter you sent on March 8 will be satisfactory if you modify the second and third paragraphs to read as follows:; >>>'Federal Regulations 49 CFR Part 567, *Certification*, requires Blu Bird to certify the front and rear gross axle weight rating (GAWR) and the gross vehicle weight rating (GVWR) of completed vehicles, and specifies a minimum GVWR based on seating capacity.; 'Your vehicle may be shipped as it is, however, the values of GAWR an GVWR shown on the certification plate will be contingent on the chassis modifications indicated above. These changes *must*, in the interest of safety, be made before the vehicle is placed into service, and you should take the vehicle to your chassis dealer as soon as you receive it.'<<<; 4. Send copies of each such statement to (a) Office of Standard Enforcement, National Highway Traffic Safety Administration, Washington, D.C. 20590, (b) the manufacturer of the chassis that was delivered to you, and (c) the dealer from whom the buyer ordered the chassis, if any and where known to you.; This procedure is allowed only as to chassis that have already bee received by Blue Bird as of the receipt of this letter, and it should not be viewed as precedent for future action by any other persons. In the future, Blue Bird as the final-stage manufacturer must take responsibility for the vehicle as completed by it, to the extent of its knowledge of relevant facts.; We are pleased to be of assistance. Sincerely, Lawrence R. Schneider, Chief Counsel |
|
ID: aiam1953OpenMr. J. W. Kennebeck, Manager, Emissions, Safety & Development, Volkswagen of America, Inc., Englewood Cliffs, NJ 07632; Mr. J. W. Kennebeck Manager Emissions Safety & Development Volkswagen of America Inc. Englewood Cliffs NJ 07632; Dear Mr. Kennebeck: This responds to Volkswagen of America's March 25, 1975, petition fo rulemaking to amend S4.5.3.3 of Standard No. 208, *Occupant crash protection*, to allow, at the manufacturer's option, visual warning lamps which remain activated whenever front outboard safety belts are not in use. Your petition states that it supersedes Volkswagen's February 20, 1975 petition for rulemaking.; Your petition explains that Volkswagen, in offering a passive bel system in its Rabbit model on an optional basis, provides an ignition interlock system and a passenger-side warning system to encourage passive belt usage, although such systems are not required by the standard. You correctly note that a January 16, 1975, letter to Volkswagen from the NHTSA Office of Chief Counsel indicates that additional safety devices such as these are not prohibited by our minimum safety standards, as long as their installation does not have the effect of causing required systems not to comply.; Your petition requests an amendment of Standard No. 208's warnin provisions to permit a visual warning longer than the 4- to 8-second reminder light presently required by S4.5.3.3. You apparently have concluded that language in our January 16 letter prohibits the provision of any additional visual warning with a duration different than 4-8 seconds.; Our January 16 letter states 'additional [safety] devices could not b installed if that installation has the effect of causing the required systems not to comply.' This does not prevent the installation of a second visual warning which operates continuously when seat belts are not in use at either front designated seating position. The manufacturer who provides such additional warning would only have to ensure that the required 4- to 8-second visual reminder required under S4.5.3.3 operates independently of the additional warning.; For this reason, we conclude that Volkswagen may provide the additiona warning it desires without amendment of Standard No. 208. Accordingly, Volkswagen's petition is denied as unnecessary. Please advise the NHTSA if this interpretation does not permit Volkswagen to provide the degree of additional warning for which it petitioned.; Sincerely, Robert L. Carter, Associate Administrator, Motor Vehicl Programs; |
|
ID: aiam5013OpenThe Honorable Dave Durenberger United States Senate Washington, D.C. 20510-2301; The Honorable Dave Durenberger United States Senate Washington D.C. 20510-2301; "Dear Senator Durenberger: Thank you for your letter of April 28, 1992 concerning a product developed by your constituent, McNaughton Incorporated of Minneapolis, Minnesota. The product is a device to prevent a child from opening the buckle of a safety belt without adult assistance. You requested information on any regulations that pertain to this product. The agency has received inquiries about similar products in the past. While we understand parents' concerns that young children should not be able to easily get out of a safety belt, we have significant reservations about these types of products because they could significantly increase the difficulty of using the buckle release and thus hinder a person attempting to release the belt in an emergency. I am enclosing an August 6, 1986, letter from NHTSA's Chief Counsel to Ms. Ann Boriskie. As this letter explains, your constituent's product could not be installed by a commercial entity without violating Federal law. In addition, installation of your constituent's product by any person would be inconsistent with this agency's policy to encourage vehicle owners not to remove or otherwise tamper with vehicle safety equipment. You also asked for information on how McNaughton Incorporated could become involved in the national safety belt campaign. The Agency is currently working with a variety of public and private sector organizations to increase safety belt use to 70 percent by the end of 1992. The strategy focuses on increased law enforcement efforts coupled with aggressive community-based public information. There are many ways McNaughton can support these efforts. They can consider developing and implementing an in-house safety belt education program targeting their employees or applying for the 70 percent Honor Roll Program. They might be interested in supporting community awareness initiatives that promote the campaign, including the posting of billboards and the inclusion of safety belt messages in their on-going advertising. An expanded list of ideas is attached. If McNaughton Incorporated is interested in additional campaign information, they can contact Susan Gorcowski, Office of Occupant Protection, (202) 366- 2683. I appreciate your interest in the safety of motor vehicles and hope this information is helpful. Sincerely, Jerry Ralph Curry Enclosures"; |
|
ID: aiam0211OpenMessrs. Ganglberger and Goerter, Semperit, Oesterreichish-Amerikanishe Gummiwerke Aktiengesellschaft, Werke 2, A-02514 Traiskirchen, N.Oe., Austria; Messrs. Ganglberger and Goerter Semperit Oesterreichish-Amerikanishe Gummiwerke Aktiengesellschaft Werke 2 A-02514 Traiskirchen N.Oe. Austria; Gentlemen: Thank you for your reply to our letter of December 11, 1969 concernin tires marked with the legend 'Farm Use Only Tires'.; Concerning the question you raise in your letter relating to the DO symbol, Standard No. 109 requires that the symbol be between the maximum section width and the bead to protect the lettering from obliteration during use. Therefore, placing the DOT symbol at the widest place on the side wall rib as illustrated in your enclosed drawing would not be permitted.; With regard to your question asking if the approved symbol and th manufacturer's code mark is necessary, the approved symbol signifies that the manufacturer certifies that the tire complies with the Standard and is, therefore, necessary. Tires exported to this country without the symbol would be in violation of the National Traffic and Motor Vehicle Safety Act of 1966. The code number is only required if your company manufactures a tire with a brand name other than its own, The purpose of the code number is to identify the manufacturer of the tire.; Sincerely, Lawrence R. Schneider, Assistant Chief Counsel, Moto Regulations; |
|
ID: aiam3597OpenMr. F. E. Bettridge, Board Chairman, Middlekauff, Inc., 1615 Ketcham Avenue, Toledo, OH 43608; Mr. F. E. Bettridge Board Chairman Middlekauff Inc. 1615 Ketcham Avenue Toledo OH 43608; Dear Mr. Bettridge: This is in reply to your petition of July 16, 1982, for a temporar exemption from Federal Motor Vehicle Safety Standard No. 301, *Fuel System Integrity*.; You have told us that 'as a seller and installer of truck bodies, w are frequently called upon to install a body on an incomplete vehicle furnished to us by a major manufacturer through his dealer.' Our regulation on vehicles manufactured in two or more stages (49 CFR Part 568) requires the manufacturer of an incomplete vehicle to furnish, with the vehicle, statements with respect to each of the standards which inform the final stage manufacturer of the vehicle's compliance status. With respect to Standard No. 301, each manufacturer should provide you with a statement of specific conditions of final manufacture under which the completed vehicle will conform or, alternatively, a statement that the vehicle when completed will conform if no alterations are made in identified components of the incomplete vehicle.; These statements afford a basis for your certification of complianc with Standard No. 301 without the necessity of testing. We would like to know which of these statements have been provided and why you may believe your manufacturing operations are such that you could not certify compliance with Standard No. 301.; We would also like to make clear that there is no legal requiremen that you crash test a $10,000 vehicle in order to demonstrate compliance. Certification may be based upon computer simulation, mathematical calculation, or engineering studies. Upon reflection you may decide that you have an adequate basis for certification with Standard No. 301.; Until we hear further from you, we shall hold your petition i abeyance.; Sincerely, Frank Berndt, Chief Counsel |
Request an Interpretation
You may email your request to Interpretations.NHTSA@dot.gov or send your request in hard copy to:
The Chief Counsel
National Highway Traffic Safety Administration, W41-326
U.S. Department of Transportation
1200 New Jersey Avenue SE
Washington, DC 20590
If you want to talk to someone at NHTSA about what a request for interpretation should include, call the Office of the Chief Counsel at 202-366-2992.
Please note that NHTSA’s response will be made available in this online database, and that the incoming interpretation request may also be made publicly available.